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By Richard DeSylva RH DNM

The Canadian experiences with Natural Health Product regulations, similar to those adopted by South Africa

Richard DeSylva RH DNM

Richard DeSylva RH DNM

About Richard
Richard DeSylva started the Canadian Herb Works Company in 1977, and has been committed to providing premium quality herbs and herbal formulae to clientele, natural food stores, and distributors around the world. He is a Registered Herbalist and Doctor of Natural Medicine. He is currently the Vice-president (Eastern Canada), Canadian Association of Herbal Practitioners and Board Member, Canadian Council of Herbal Associations. Richard is a founding member of our Canadian alliance partner organization, Canadian Natural Products Alliance.

It has been a little more than 10 years since the Natural Health Product Directorate (NHPD) officially brought into force the regulations governing the manufacture & sale of what are now known as ‘NHPs’ (Natural Health Products) in Canada.  While it may well be argued that there is greater validity and social sanction given to these substances, the trade-off seems to have been that the Natural Non-Prescription Products Directorate (NNPPD) will only assign a Natural Product Number (NPN) when given the purely ‘scientific’ confirmation of therapeutic efficacy.

My argument is not with this aspect of investigational science; I honestly welcome the validation of its prior traditional usage for the knowledge that it imparts.

The issue at hand though, is the ‘drug’ model used in trying to interpret the host of bio-chemical substances found in a plant.

This laser beam focus on key active ingredients separates certain classes of compounds, from anything else that remains. There is no interest in any synergists, mineral salts, mucilage (glycoaminoglycans) or other such secondary and tertiary compounds. To the medical/ scientific mind, it is merely some sort of detritus, and unworthy of further examination or consideration of how they fit within larger therapeutic matrix.

For this reason it bears reminding of the findings and recommendations of the NEW VISION Report (1998) accepted by then Minister of Health Allan Rock. This Report was based upon a year-long interview with various stakeholders, academia, scientists, etc.

In their opening comments in the introduction and later, in the body of the Report, they specifically stated that these substances were neither drugs, nor foods (in the common understanding of the term ‘food’), but incorporated elements of both. It was for this specific reason, they stated, that the ‘drug’ model was an inappropriate regulatory model for these substances; and that a new model was required for regulation.

Health Canada agreed to implement the findings of this Report, and launched the Office of Natural Health Products (ONHP), later to be known as the Natural Health Products Directorate (NHPD), and now the Natural Non-Prescription Products Directorate (NNPPD).

Unfortunately, later on in early 2001, the draft documents came out for ‘Standards of Evidence’, and the Good Manufacturing Practices (GMPs) for this supposed new regimen.

I critiqued these draft documents, and found that they were in effect, an identical copy of the ‘drug’ GMPs. I know this to be certain, as the scribe for Health Canada had simply replaced the word ‘drug’ with that of NHP (Natural Health Product).

However, he must have been asleep at the switch, as he forgot the last two pages of this 20+ page document; there in unblemished copy was the word ‘drug’, and not ‘NHP’.

What is needed here is an acknowledgement of a different but equally valid model of therapeutic rationale.

This rationale has its origin in the perception of the early eclectic and physio-medicalist practitioners (the forerunners of the medical herbalists (phytotherapists) and modern naturopaths), who saw herbs as ‘nutritive, sanative and restorative’. They understood that herbs provided a measure of nutrition (‘nutritive’);  that they were health giving (‘sanative’) and most importantly, that, over time, they were truly ‘restorative’, and could rebuild tissue and bring the human organism back to a healthy state.

Many herbs, and specifically – many herb formulae, contain compounds such as mucopolysaccharides, mineral salts, essential oils, astringents and other co-factors that address the bio-chemical deficiencies of chronic, degenerative disease.  It is these same components that – in a properly constructed herbal formulation, can change a diseased state back into a condition of health.

As an example, in cases of degradation of the mucosa (mucus membranes) of the intestinal tract, such as ulcers, or worse still, diverticulitis, Crohn’s or irritable bowel syndrome (IBS), this mucus layer needs to be rebuilt and restored to its proper state of being; the characteristic inflammatory process needs to be addressed; the fungal component must be dealt with, and last but not least, the emotional component requires attention.

In support of this approach, and by way of background, back in the early 1960’s, Dr. Orville Miller (1) studied  what were then called ‘mucopolysaccharides. He was quite taken with their extremely low toxicity, and because of their high molecular weight, believed that they would be very useful in rebuilding tissue.

Thus, in treating the above noted ailments, one of the most important types of herbs used is that of the demulcent: the mucilaginous, soothing emollient that will coat the abraded surface, and over time serve to rebuild this protective coating.

Herbs such as Marshmallow root (Althea officinalis), Slippery Elm bark powder (Ulmus fulva), or possibly even Comfrey Root (Symphytum officinale) [only under the care & guidance of a Registered Herbalist] contain this mucilaginous compound formerly known as mucopolysaccarides, now called glycoaminoglycans.

In addition to these herbs, one must add Chickweed (Stellaria media) – and its nascent Sodium, for its ability to counter inflammation; an astringent such as Purple Loosestrife (Lythrum salicaria) to astringe the swollen tissues and bring them back down to normal tone.  Equally, simple Catnip (Nepeta cataria) can be added to reduce irritation & hypersensitivity of the tissues, so characteristic of these conditions. Finally, a good anti-fungal agent: whether it be Walnut Hull (Juglans nigra) tincture, or Olive Leaf (Olea europaea) tincture will address the fungal component of this condition.

Implicit in the above, is the recognition that these herbs will provide the phyto-nutrients necessary for the ultimate resolution of the aforementioned conditions. Unfortunately, the addition of herbs such as Chickweed (Stellaria media), Purple Loosetrife, (Lythrum salicaria) or even Marshmallow root (Althea officinalis) would not be recognized as being an ‘active’ ingredient.

I say this as back in 2010 in Oxford Missouri, Robin Marles, one of the early scientific advisors of the NHPD, dismissed the addition of herbs such as these as little more than “fairy dusting”. This was and still is, typical of the mindset of NHPD, now known as NNPPD.

Having inquired of a couple of industry consultants close to the NNPPD, if there was any chance of recognition of this ‘food’ component of herbs, I was advised that no, it would only be “active” ingredients & only those with a strong demonstrated background of scientific support that they would recognize.

Sadly, it is thus a moot point whether or not there will be a change in this regard, in spite of the original recommendations of the NEW VISIONS Report. However, if one is to properly understand herbal medicine, and to use it to advantage in dealing with the ever more serious diseases today, it is absolutely necessary to remodel our view of herbal therapeutics.

While the ‘active’ ingredients in herbs are to be used to advantage, to view only those validated herbs as being worthy of note, is fallacious at best, and at worst, ignorant of the true nature of herbal medicine, and its use of multi-faceted / multi-component herbs.  And, to come back full circle, many of a herb’s constituents are more than just an ‘active’, they are nutritive in nature, providing necessary compounds that serve to restore normal values and parameters to the integrity of tissue and function.

Given the above advice re: NNPPD’s outlook, it is readily apparent that what we are witnessing today, is the drug-ification of herbs.

It is the continuation of the ‘germ model’ of thinking about disease causation, assigning an overwhelming level of importance to pathogenic entities, and thus the need to eliminate them with “active” ingredients only, by whatever means: synthetic or natural.

To consider changing the underlying terrain – as was the focus in the work of Dr Gunther Enderlein (2) in his massive work “BACTERIAL CYCLOGENY” is shunned as being without foundation, and of no importance in dealing with the growth of various pathogenic entities.

Such scientific ignorance is profoundly disappointing, and indicative of the hold that modern medicine has in perpetuating the germ theory of disease and it attendant corollaries.

The problem with this model is that it ignores the various underpinnings of the disease process: the unbalanced ratio of acid to alkaline / base values in the blood & tissues, itself brought on by poor functional activity of the filters of the body: the kidneys and liver.

Ideally, the blood should be slightly alkaline, with the tissues slightly acidic; the body is similar to a battery, and must have a difference in electro-potential, in order for innate bio-chemical processes to take place. Mineral ratios: Potassium vs Sodium; Magnesium vs Calcium; Iron vs Manganese, and many, many other relationships & counterbalances, must be there in proper ratios to achieve a healthy state.

When there is imbalance and the blood & tissue become very acidic, pathogenic entities mutate into more virulent forms; conditions such as arthritis occur due to attempts at rebalancing the pH by robbing the body of alkaline Calcium from the bones.

In this low Oxygen environment (due to higher Hydrogen ion component of acids) conditions such as candidiasis develop. This in turn is a major component of a variety of conditions such as male & female reproductive tract issues, IBS, MS, a host of auto-immune disorders, and even cancer.

The thrust of traditional medicine: specifically herbal medicine has always been to achieve a restoration of basic systems that contribute to that imbalance. These systems: digestion / alimentation, blood & circulatory system, elimination ( bowels & kidneys) nerve force, and respiration / oxygenation, all contribute – by reason of their poor functional activity, to the imbalances noted above.

Further, there is the more modern addition to this knowledge base, of the phenomenon of biological transmutation (3), that sheds tremendous light upon the understanding of how this ebb & flow of acid vs base, fluctuates according to both need, as well as intention of the moment.

Sadly, there is a profound lack of interest in, and knowledge of these principles, because they don’t fit within and support the ‘germ model’ as noted previously. Were this otherwise, our world would indeed have a much healthier populace.

A number of years ago, Jesse Sleeman a herbalist of some repute in Australia, lamented the fact that there is no longer a cohesive and coherent body of knowledge underlying the practice of Phytotherapy (Medical Herbalism).

What I have attempted in the preceding pages is to try and address some basic ideas that reflect this fading body of knowledge.  It is still there in some of the older texts of the early practitioners such as Dr Schook, Dr Bernard Jensen, his mentor – V.G. Rocine, etc. and was taught by my own mentor Dr Albert J Thut N.D. MNIMH ( Guelph , Ont)

I would suggest that it is past time to rethink the modern position on herbs and what they offer. If we ignore the ‘food’ nature of herbs; if we ignore their rightful place in the armamentarium of herbal therapy, and if we ignore the fading body of knowledge inherent in traditional herbal medicine, we have only our outlook to blame.

The rise of highly resistant pathogens, the increase in new and different diseases is due to this abandonment of the older body of knowledge, and its primary focus on maintaining health & wellbeing.

The result is that our bodies are becoming very diseased due to build-up of waste & other toxic matter – both in our diet and in the environment.  At the risk of sounding alarmist, it might well be said that the four horsemen of the apocalypse are on the horizon.  What defenses are left if we ignore what lies hidden in Nature’s bounty, and in the manifold secrets of her vegetable medicines?


  1. “Nutritional Aspects of Mucopolysaccharides” an information paper by Orville M, Miller, Ph.D. University of Southern California School of Pharmacy.)
  2. “Bacterial Cyclogeny” Dr Gunther Enderlein Enderlein Enterprises Scottsdale Arizona.
  3. “ Biological Transmutations” Louis Kevran Swan House Publishing Co. N.Y.
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